A complete PFAS test panel takes between two and six weeks - and laboratories will be heavily overloaded in the run-up to the 12 August 2026 deadline. Companies that only start sending supplier PFAS inquiries in spring 2026 risk, according to industry experts, still placing non-compliant products on the market in the fall. The bottleneck is not only the testing itself, but above all supplier communication: collecting, checking, validating, and fully documenting data - with dozens or even hundreds of suppliers at the same time.
This article shows how to set up PFAS-related supplier communication in a structured, efficient, and audit-proof way - and why automation is the difference between compliance assurance and compliance chaos.
Why PFAS compliance is a supplier challenge
The PPWR (Regulation (EU) 2025/40) bans PFAS above defined limits in all food contact packaging from 12 August 2026 onwards. The three key thresholds are: max. 25 ppb for individual non-polymeric PFAS, max. 250 ppb for the sum of non-polymeric PFAS, and max. 50 ppm for total fluorine (Anthesis Group). Crucially: The PPWR does not distinguish between intentionally added and non-intentionally present PFAS (Anthesis Group).
For companies, this means you cannot ensure PFAS compliance purely internally. The relevant data - material composition, coatings, processing aids - sits with your packaging suppliers. This is exactly where the problem begins:
- Many suppliers themselves do not have complete composition data because they rely on their own upstream suppliers (Certivo)
- Traditional email questionnaires result in inconsistent response formats and a high manual review workload
- A PFAS laboratory test typically takes between two and six weeks (Lovat Compliance) - bottlenecks are foreseeable from Q2 2026
- According to the draft EU guidance, a supplier declaration alone is not sufficient for compliance - laboratory results are required (Lovat Compliance)
If you would like to dive deeper into the details of PFAS documentation for audits, the article PFAS compliance in packaging management: Documentation for PPWR and REACH audits provides a comprehensive overview.
What a robust PFAS supplier questionnaire must include
An effective PFAS inquiry goes far beyond the question "Do your products contain PFAS?". For audit-proof documentation, your standardised questionnaire should address the following points:
- Explicit PFAS statement per material/item number: Not a blanket statement, but linked to specific specifications
- Reference to the PPWR limits: 25 ppb (individual), 250 ppb (sum), 50 ppm (total fluorine)
- Indication of the test method: Has a total fluorine screening been carried out? Are targeted analytical results available?
- Validity and versioning: Date of the declaration, validity period, reference to the obligation to renew in the event of formulation changes
- REACH compliance statement: In addition to PPWR, information obligations on SVHCs (> 0.1% by mass) should be covered
Practical tip for procurement managers: Integrate the PFAS questionnaire into your regular supplier qualification - as a fixed part of the onboarding and review process.
Five steps to structured PFAS data collection
The following process helps you set up supplier communication systematically - from the initial inquiry through to audit-ready documentation:
Manual vs. automated: The practical efficiency gap
For companies with 50 or more packaging suppliers, manual PFAS data collection via email and Excel quickly becomes a resource drain. The following comparison shows where automated supplier communication offers concrete advantages:
Companies that rely on manual processes typically achieve only a 30-50% response rate from supplier inquiries after four weeks - automated platforms with structured reminders and self-service portals significantly increase this rate.
How Packa automates PFAS supplier communication
The Packa software for digital packaging management is designed to address exactly these PFAS-related supplier communication challenges:
- Automated supplier questionnaires: Send standardised PFAS questionnaires directly from the platform to all relevant suppliers - with deadlines, automatic reminders, and escalation rules
- Real-time data validation: The platform automatically checks incoming responses for completeness and plausibility. Missing information or inconsistencies are flagged immediately
- Direct link to packaging specifications: The platform automatically assigns PFAS declarations and laboratory reports to the relevant packaging specification - as the basis for the PPWR declaration of conformity
- Gap analysis at portfolio level: See at a glance which packaging items still lack PFAS evidence - and target your follow-up actions accordingly
- Audit-ready documentation trail: Every communication step is logged - from dispatch and reminders through to final validation
If you want a comprehensive overview of the PFAS ban and its impact on food packaging, the article PFAS in food packaging: What the 2026 EU PFAS ban means provides the relevant background.
Your next steps: Act now instead of reacting in summer
Most food companies need four to nine months to replace a non-compliant supplier - including material testing, artwork updates, and inventory clean-up (Lovat Compliance). This means: if you start now, you still have time for an orderly transition process. If you wait, you risk being excluded from markets.
Three concrete recommendations for action:
- Immediately: Identify all food contact packaging in your portfolio and prioritise high-risk formats (coated papers, board with recycled fibre content, fast-food packaging)
- Within 4 weeks: Send standardised PFAS questionnaires to all affected suppliers - ideally via a central platform with automatic follow-up
- Ongoing: Validate incoming data, request missing laboratory reports, and link all evidence to your packaging specifications as the basis for the declaration of conformity
The free PPWR checklist helps you quickly assess the current compliance status of your portfolio.
